Legal compliance in business operations is an indispensable condition that every corporation must satisfy to fulfill its responsibilities to society. The TOPPAN Group firmly believes that every person working in the Group must fully recognize the importance of compliance, make proper judgments, and act with integrity under high ethical standards by respecting laws, regulations, in-house rules, social norms, and other standards of conduct.

Risks related to compliance increase as we globalize our business and intensify our operations beyond borders.

In 2000 we established a set of Conduct Guidelines based on the Corporate Philosophy and Corporate Creed. The guidelines were, and continue to be, a collection of fundamental provisions that set out the basic concepts and behavioral norms for employees to follow in accordance with corporate ethics and the principles of legal compliance. Ten years later, in response to shifts in business environments and social conditions, we completely revised the guidelines into the TOPPAN Group Conduct Guidelines, a set of principles that all Group companies around the world are required to observe. A second full-fledged revision of the guidelines took place in April 2021, based on a comprehensive review conducted in 2020. The latest Basic Principles in the guidelines call upon Group employees “(to) achieve a sustainable society” and strive for “personnel diversity,” a “rewarding work environment,” and other sustainability requirements. The latest guidelines will guide accelerated efforts to address the material issues propounded in the TOPPAN SDGs STATEMENT, and observance of them will help shape a sustainable society.

The TOPPAN Group Conduct Guidelines have been formed as a set of basic rules to be fully observed by employees to ensure the legality of the execution of job duties. The Compliance Department set up under the Legal Division coordinates with the legal departments and other related sections of our subsidiaries to secure legal compliance and establish corporate ethics across the Group. A Conduct Guidelines Promotion Leader (“Leader”) system supports guideline compliance in workplaces in the Group. Leaders appointed under the system work to enforce guideline compliance in daily operations under the Director in charge of Conduct Guidelines Promotion.

Specifically, the Director in charge of Conduct Guidelines Promotion (Executive Vice President & Representative Director) heads the Leader system and supervises compliance promotion activities. The Leaders appointed at workplaces arrange training programs at their sites and report locally arising questions and consultations to the Director in charge of Conduct Guidelines Promotion via administration offices.

Disciplinary provisions in our employment rules, meanwhile, stipulate disciplinary actions for serious violations of laws, regulations, the Conduct Guidelines, and other in-house rules. Our personnel performance evaluations and evaluations for bonuses and annual salary revisions also weight criteria focused on legal compliance, corporate ethics, and environmental protection, to better ensure that our social obligations are optimally fulfilled.

We have been undertaking various anti-corruption initiatives in conformance with the anti-corruption principles set out by the United Nations Global Compact. The TOPPAN Group Conduct Guidelines affirm wide-ranging principles on corruption prevention, such as the “prohibition of bribery and inappropriate entertainment practices,” “prohibition of receipt or provision for personal gain or rebate,” “prohibition of illegal political contributions or donations,” and “prohibition of collusion and cartels.”

To better combat bribery, we established a set of anti-bribery rules and guidelines in March 2017 and formulated an anti-bribery framework led by the Director in charge of the Legal Division as the chief anti-bribery manager. For more intensive anti-bribery control, we launched a system requiring pre-authorization for the offering of any entertainment or gifts to a public official or the like. An FAQ describing specific cases of bribery was issued in April 2018 to further heighten employee awareness and call strict attention to compliance-related issues. As a basic rule, employees are prohibited from making “small facilitation payments” (payments to facilitate or expedite routine governmental services such as visa issuance or customs clearance) to public officials.

Illegal contributions and funding provision are also comprehensively prohibited throughout the Group. Any form of association or contact with anti-social forces, for example, is clearly prohibited in the TOPPAN Group Conduct Guidelines and the Guidelines on Dealing with Anti-social Forces. No cases of inappropriate entertainment or gifts to public officials or the like were identified in fiscal 2022.

In training sessions organized each year for candidates for overseas assignments, trainees learn reinforced strategies to combat bribery in the commercial and public sectors and become familiar with the pre-authorization system. Twenty-six employees attended six sessions in Japan in fiscal 2022.

We have also been formulating anti-bribery rules for overseas affiliates across the Group. Rules of this type were established at Group affiliates in Shanghai, China in fiscal 2021. Briefing sessions were held for Shanghai-based employees in fiscal 2022.

We continue to win more contracts with national and local governments. To ensure proper compliance and conduct, we held a series of training sessions on antimonopoly legislation in fiscal 2022. A total of 1,597 persons, primarily from related companies, attended the sessions.

Political Contributions and Other Expenditures

To observe major transaction-related laws and regulations, we have been promoting compliance with the Subcontract Law of Japan and comprehensively preventing improper import and export transactions.

In fiscal 2022, a total of 2,644 employees from departments that customarily conduct transactions with subcontractors were trained on compliance with the subcontract law, and 10,336 employees took an e-learning course on export controls under the Foreign Exchange and Foreign Trade Act of Japan. We also audited compliance with the subcontract law in 62 departments and the observance of export controls in 35 departments.

The audits in fiscal 2022 confirmed conformance with these laws across the Group. No serious legal violations or cases of misconduct were identified, and no problems or incidents occurred in transactions with subcontractors or import or export transactions.